Enterprise Wireless Insider, Volume 11, Issue 12

FCC Releases 900 MHz NOI

Earlier this month, the Federal Communications Commission (FCC) released a Notice of Inquiry (NOI) to “begin a proceeding to examine whether any rule changes may be appropriate to increase access to spectrum, improve spectrum efficiency, and expand flexibility in the 896-901/935-940 MHz band (900 MHz) for next generation technologies and services.” 

The FCC releases an NOI when it is less than certain how it wishes to proceed. NOIs present general and specific questions to help the FCC gather industry viewpoints and to determine whether to proceed to the next step in the regulatory development process, possibly a Notice of Proposed Rulemaking. 

The NOI includes discussions of the Joint EWA/PDV Petition for Rulemaking, which proposes bifurcating the band to create a private carrier broadband allocation focused on business enterprise users, including critical information infrastructure (CII), and the M2M Networks, Inc. proposal to allow all Business/Industrial Land Transportation (B/ILT) spectrum to be used for an Internet of Things (IoT) service to B/ILT-eligible entities. 

The FCC’s inquiry includes questions about the costs and benefits of various approaches to band renovation, including the possibility of providing for a 5X5 broadband allocation or leaving the band as is. Comments are due on September 18, and Reply Comments on October 18. (WT Docket No. 17-200) 

Public Safety’s Spectrum Reach Clarified

The Enterprise Wireless Alliance (EWA) has reiterated its support of the Arizona Public Service Company’s (APSC) Request for Waiver and, concurrently, responded to comments filed by Association of Public-Safety Communications Officials-International, Inc. (APCO) that suggested an unfamiliarity with the APSC filing and the FCC’s rules governing access to the 800 MHz Expansion Band (EB).

While not directly opposing APSC’s request, APCO’s comments suggested that it failed to read it thoroughly, and that they apparently misunderstand the pool allocation of EB spectrum in the 800 MHz Band. APCO urged the FCC to hold APSC “accountable and ensure that [APSC] will immediately act, at its own cost, to resolve any issues it causes that impact the needs of public safety licensees to access channels during the rebanding process.” Perhaps unnoticed by APCO, the 800 MHz Transition Administrator (TA) had previously provided its concurrence of APSC’s requested channels. 

APCO also claimed that certain “public safety licensees are eligible for EB channels” and would benefit “from the priority under consideration.”  If it were only true. In a 2015 Public Notice, the FCC made it clear that the few public safety licensees already licensed on EB channels could remain, but that any new public safety entities are ineligible for the spectrum in the Expansion Band. APSC, on the other hand, is fully eligible as a Business/Industrial Land Transportation licensee.

Spectrum Stewardship Critical

In an ex parte letter, EWA affirmed its support of rules on license renewal and discontinuance of operations protocols proposed in a draft FCC Second Report and Order (Order). EWA urged the Commission to reconsider its decision to exempt Public Safety entities from the obligations referenced in the Order. Should the Commission proceed to exempt public safety licensees from certifying the accuracy of their operations at time of license renewal and from the obligation to notify the FCC when any portion of their licensed service is permanently discontinued, EWA asked how it would be possible to rely on the validity of the FCC’s Universal License Service database regarding actual public safety spectrum use. 

If the FCC proceeds as planned, EWA urged the Commission to reject, as insufficiently supported, all future public safety waiver requests that seek use of Industrial/Business (I/B) channels. “Public safety requests to access Industrial/Business are pursued, in part, on assertions that there is no public safety allocated spectrum available for a public safety applicant. Without public safety’s participation as a spectrum steward, assertions that there is no available public safety spectrum are essentially baseless,” stated EWA President Mark Crosby.

Public Safety Waiver Protocols Needed to Safeguard I/B Spectrum

EWA has proposed informational sharing processes among Business/Industrial frequency advisory committees in the event any Public Safety (PS) frequency advisory committee (FACs) seeks to access Business/Industrial spectrum on behalf of a public safety entity. Such requests require justification coupled with a waiver request.  Critical to the process is the public safety FAC’s assertion that there is absolutely no public safety spectrum availa-ble for the applicant.   

EWA has initiated acceptance of this process because some B/ILT FACs do not conduct a separate analysis to determine the veracity of the claim that no PS spectrum is available to meet the needs of the applicant.   

6 GHz Microwave NOI Released

On August 3, the FCC adopted an NOI examining frequencies between 3.7 GHz and 24 GHz (“Mid-Band”) to begin the process of determining whether spectrum in this range can be made available for wireless broadband use, focusing on potential opportunities in bands allocated for exclusive non-federal use and for shared federal and non-federal use. While recognizing that there are approximately 27,000 6 GHz microwave licenses, the NOI none-theless asks whether there is potential for additional flexible wireless broadband use in the 5.925-6.425 GHz band. EWA believes this will be a difficult band to share but notes that the no one group is escaping a request to share in this NOI. Government and non-government entities alike are included. Comments are due on October 2; Reply Comments are due November 1. (HG Call sign E150095; GN 17-183)

A Word from Don Pierson: Future Techs?

Thanks for the comments that I received on my last article about the future of the Electronics Service Industry.  It dealt with the availability of technicians for the future and what we can do to help find the talent that we need to provide critical resources to the economy.   I would like to make a couple additional points about the situation that exists to develop this key resource for the future, and also share some facts about what we can all do to help promote a challenging career opportunity for young men and women.

Teresa Maher with ETA shared some facts with me that she learned at the SKILLS USA Meeting about the need for trades people in this Country right now. There are critical shortages in qualified people to perform maintenance, repair, and installation work right now. For example, I can see my Doctor in a day or two, but my call to the plumber, carpenter, or wireless product could very well take longer. Another unfortunate but frequent comment made by far too many is that the person sent out to do the work couldn't fix the item after looking at the problem. Many claim to be professionals but are far from it when you look at their actual training and experience. Recently I had a personal experience where an air conditioner went out so I called a highly regarded service company with whom I had a maintenance agreement, and 10 days after my request, they came out to fix it.  He informed us that they would have to get us a new unit and that would take another 10 days to deliver. Many claim to just replace broken units under warranty but someone still has to review the problem and make an informed decision as to whether to fix or replace. That is still a technician of some level making that call and also hopefully a qualified person reinstalling the defective product. The 10 days it took to get the service call completed was undoubtedly due to more work than the existing techs could handle in a reasonable time frame and also perhaps the skill sets needed to actually repair many of the units that they try to fix in the field. 
 
Mike Rowe, actor and proponent of skilled trade development also well known for his role on The Discovery Channel's "Dirty Jobs" was recently on a Cable News Program as a spokesperson for an Organization called Skills USA and stated that there are 6 million jobs available right now in the trades and that emphasis today in the educational institutions is to get a four-year degree.  Very little emphasis is given to pursuing the trades that include the technical services that are provided by our Certified Service Centers. The next question is if there is currently any interest in these vocations by young people today? Apparently, there is based on Mr. Rowe's comment that in SKILLS USA, an organization that promotes interests and education in the trades nationwide.  There are currently 400,000 young people involved in that organization who currently have an interest in pursuing a career where they fix and build things and those are just the kind of folks that we are trying to find. In fact, this is an organization you should take a close look at because they have chair people for every State that are named on their web site www.skillsusa.org.  Contact them and see if you can get involved locally and perhaps even find someone in your own area who might fit into your business as a future technician.
 
If we want to get some action fast we will have to do it ourselves at the local level plus influence government officials and local school and business associations to help them realize that we have a lot of jobs available right now if we just redirect the emphasis of our educational and vocational counselors. Just think if we could fill 6 million jobs with people interested in the trades, what a problem solver that would be. Please make sure your local politicians know that fact. Ask yourself the question as to what young people even know about a career in a technical service industry?  The answer is nothing because no one has ever taken the time to explain a career like that to them. That teacher could be you. Offer to speak at the high schools and tech schools and tell them the story about this career and what is has to offer and then offer to mentor students who have the aptitude and ability to become one of your future technicians. Also, once you have found the right person get them trained through the proper Certification and Industry Associations like PSA, ETA and TRN who have done a great job helping to get the training that your folks will need once you bring them on board. 
 
Don Pierson
Certified Service Center

FCC Receives Full Complement of Commissioners

On August 11, the Senate confirmed Brendan Carr (R) and Jessica Rosenworcel (D), President Trump nominees, to the Federal Communications Commission. The Senate postponed reconfirmation of Ajit Pai as Chairman. 

Within days, Carr named acting staff, including Kevin Holmes, Acting Legal Advisor for Wireless and Public Safety. Prior to this role, Mr. Holmes worked on spectrum, mobile broadband, and public safety issues with the FCC Office of Legislative Affairs.

Chairman Pai has named Jennifer Tatel Acting Counsel to replace Mr. Carr. Ms. Tatel recently served as Chief of Staff and Deputy General Counsel.

AIRWAVES Legislation

The “Advancing Innovation and Reinvigorating Widespread Access to Viable Electromag-netic Spectrum Act” (AIRWAVES) has been introduced in the Senate. The bill proposes identifying what is now termed “Mid-Band” spectrum for both licensed (auctioned) and unlicensed use with an emphasis on rural deployment.  

FCC Advisory Reminds Civil Aviation Not to Abuse Emergency Frequency

In an Advisory released August 8, the FCC Enforcement Bureau stated that increased use of 121.500 MHz for non-emergency communications is impairing the ability of the Federal Aviation Administration to monitor the channel for emergency purposes. The notice warns that the FCC “will aggressively enforce the rules related to aviation radio operations.”